COURT OF FIRST INSTANCE
(interim injunction requested)
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF THE LAWSUIT : ……….. is a negative declaration lawsuit to determine that my client is not indebted.
FACTS : 1- My client … purchased … Bürosit brand office chair and an office desk from the defendant A on …………. and paid …….. (……) TL of ……. (………) TL in advance and issued a promissory note dated ………. for the remaining part.
2- Despite the fact that my client paid the aforementioned note debt on time, the defendant …. telephoned my client and threatened him by saying that he should pay the debt of …….. (………) TL, otherwise he would put the promissory note into execution. However, the promissory note is fake and my client has fully paid the debt in question.
3- Since the defendant …. may put the promissory note mentioned by the defendant …. into execution and start the proceedings, it has become necessary to file this negative determination lawsuit with a precautionary injunction against the collateral.
LEGAL GROUNDS :
EVIDENCE : Promissory note, receipts that my client has paid the debt, expert and all kinds of legal evidence when necessary.
CONCLUSION AND REQUEST : With the acceptance of our lawsuit for the reasons mentioned above; We respectfully request and demand that it be decided to determine that my client is not the debtor of the promissory note in question, to issue an interim injunction to prevent the enforcement proceedings against the defendant in order to prevent the enforcement proceedings of the promissory note, and to impose the attorney fee and trial expenses on the defendant. ../../..
Plaintiff Attorney
Lawyer. …………….
(SIGNATURE)